Privacy Policy

Effective September 13, 2016

This privacy policy covers our collection, use, and disclosure of information that Afiniti (“we”, “us”, “our”) collects through the Afiniti service, Afiniti Portal, and the Afiniti website. The use of information collected through our service is limited to the purpose of providing the service for which our clients have engaged Afiniti. Our website includes links to other websites whose privacy practices may differ from those of Afiniti. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Afiniti participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Afiniti is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. http://www.privacyshield.gov/list.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afiniti is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afiniti may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


US – Swiss Safe Harbor

Afiniti complies with the U.S.–Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Afiniti has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the U.S.–Swiss Safe Harbor program, and to view Afiniti’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.


Information Collection and Use

Afiniti does not collect personal information from clients’ customers or callers. Afiniti may collect personal information from representatives of its enterprise clients. For example, approved client employees may be registered for Afiniti Portal access. These client employees may be asked to provide personal information such as their email address. We use this information to administer your account and respond to customer service requests.

If you contact us through our website, we may collect personal information from you that you provide such as your name, email address, or phone number. We use this information to respond to your requests for information about Afiniti.


Service Providers, Sub-Processors, and Onward Transfers

Afiniti may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our clients.

Afiniti is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Afiniti complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

We will share your personal information with third parties only in the ways that are described in this privacy policy. If you do not want us to share your personal information with these companies, contact us at privacy@afiniti.com.

We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If Afiniti is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email or a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.


Access

Upon request Afiniti will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may request access, correction, or deletion of your personal information by contacting us at privacy@afiniti.com. We will respond to these requests within a reasonable timeframe.


Access to Data Controlled by our Clients

Afiniti has no direct relationship with the individuals whose personal data we process. If you are a customer of one of our clients who seeks access, or who seeks to correct, amend, or delete inaccurate data, please contact the client (the data controller) that you interact with directly. Afiniti will respond to the client’s request to amend or delete your data within 30 business days.


Choice

We process information for our clients. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.


Data Retention

Afiniti will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients. Afiniti will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you may contact us at privacy@afiniti.com.


Passive Collection and Tracking Technologies

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Afiniti and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.


Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.


Contact Us

If you are a client and would like to update or delete your Afiniti Portal account, please contact us at support@afiniti.com. We will respond to your request within a reasonable timeframe. If you have questions regarding our privacy policy or practices, please contact us at privacy@afiniti.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at TRUSTe.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

For all other inquiries, please visit our contact page or write to us at:

Privacy @ Afiniti
1700 Pennsylvania Avenue
Suite 560
Washington, DC 20006

TRUSTe Privacy Certification